🗞️ A Mother, a Daughter, and a Pay Dispute That Cost a Nursing Home an NLRB Case
An NLRB judge ruled that a Michigan nursing home illegally fired a mother and daughter after they raised pay concerns together and mentioned contacting federal labor regulators, rejecting the employer's nepotism policy defense as pretext.
A National Labor Relations Board administrative law judge has ruled that Northville Manor, a nursing home in Northville, Michigan, unlawfully fired Dejahnae Hatcher and her mother, Monique Craig, after the two kitchen employees repeatedly raised concerns about their pay and hours with supervisors and the company's corporate office.
The case turns on a set of workplace protections that have drawn steady attention from employment lawyers in recent years: the National Labor Relations Act's guarantee that workers, unionized or not, may discuss wages with one another and raise those concerns collectively without fear of retaliation. Under a legal doctrine the Board has described as "inherently concerted," conversations about pay are treated as protected group activity even when workers never formally organize, because wages are considered central to nearly every job.
According to the judge's decision, Hatcher was promoted from dietary aide to cook in 2023 but did not receive a corresponding raise. She and Craig complained to their director of nursing and to human resources, then escalated the issue to the company's corporate office, where an employee said she might contact the Labor Board if the pay issue went unresolved. The next day, the director of nursing called Craig and told her that she and her daughter were about to lose their jobs over the complaints, a statement the judge cited as direct evidence that the firings were retaliatory.
Northville Manor argued that the women were not fired but resigned after being told they had violated a longstanding corporate nepotism policy barring relatives from working in the same department and shift. The judge rejected that defense, finding the company produced no witness or documentation to support the claim and that a recorded phone call with the former director of nursing, made after the charge was filed, repeatedly tied the departures to the employees' pay complaints rather than nepotism. The judge also found the nepotism policy itself did not clearly bar the arrangement, since the two worked different shifts.
The judge ordered reinstatement, full backpay with interest, compensation for related financial harms, and a workplace notice describing employees' rights under the Act. The ruling is a recommended decision. If neither side files exceptions, it becomes final under NLRB procedure; if exceptions are filed, the case proceeds to review by the Board in Washington.
Key Points
- An NLRB judge found Northville Manor illegally fired Hatcher and Craig for jointly raising pay and hours concerns, a violation of Section 8(a)(1) of the National Labor Relations Act.
- The judge separately found the firings retaliated against the employees for mentioning they might contact the NLRB, a violation of Section 8(a)(4).
- Wage discussions among coworkers are treated by the Board as "inherently concerted" activity and protected even without an explicit plan for group action.
- The company's claim that the employees resigned over a nepotism policy was rejected for lack of supporting evidence and testimony.
- A recorded statement from the former director of nursing was cited as key evidence that pay complaints, not nepotism, drove the terminations.
- The judge ordered reinstatement, full backpay with interest, and other remedies, along with a posted notice informing employees of their rights.
Primary Source Author: Sarah Karpinen, Administrative Law Judge, National Labor Relations Board Division of Judges
Primary Source: Northville Manor, LLC and Dejahnae Unique Hatcher, Case 07-CA-326048, Decision JD-45-26 (July 14, 2026)
Primary Source Link: https://www.nlrb.gov/case/07-CA-326048
